intervene in the above captioned proceeding pursuant to the Commission s Rules of Practice and

Transcription

1 ,' ~ "',',..,)..: " ).. ;;'.., James F. Fell (ISB #2274) 900 SW Fifth Avenue, Suite 2600 Portland, OR Telephone: (503) Fax: (503) iffell~stoe1.com Attorneys for PacifiCorp l...'-.d- W fled EO' ZOOfi jut - 7 Af'1 9: L:J, c" '..l i)i, j v UTILIT Irs COt~lr'USSIOt1 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION S. GEOTHERMAL, INC., AN IDAHO CASE NO. IPC- O4- Comp lainant vs. IDAHO POWER COMPANY, AN IDAHO Respondent. BOB LEWANDOWSKI and BOB SCHROEDER Complainants vs. CASE NO. IPC- O4- PETITION OF P ACIFICORP TO INTERVENE IDAHO POWER COMPANY, AN IDAHO Respondent. PacifiCorp dba Utah Power & Light ("PacifiCorp ), by and through its attorneys of record, respectfully petitions the Idaho Public Utilities Commission ("Commission ) for leave to intervene in the above captioned proceeding pursuant to the Commission s Rules of Practice and Procedure. In support of this Petition, PacifiCorp states: Portlnd Page 1

2 PacifiCorp is an electric utility in the state of Idaho and is subject to the supervision and regulation of the Commission. The address ofpacificorp s principal place of business is 825 NE Multnomah, Portland, OR Communications to PacifiCorp concerning this proceeding should be addressed to: Bob Lively PacifiCorp One Utah Center, 23rd Floor 201 S Main Street Salt Lake City, UT Telephone: (801) Fax: (801) bob.ii veiy~jjacificorp. com and James F. Fell 900 SW Fifth Avenue, Suite 2600 Portland, OR Telephone: (503) Fax: (503) j ffell~stoe1.com PacifiCorp requests that all data requests regarding this matter be addressed to: By (preferred): datarequest~jjacificorp. com By Fax: (503) By regular mail: Data Request Response Center PacifiCorp 825 NE Multnomah, Suite 800 Portland, OR The consolidated complaints in this proceeding challenge certain practices with respect to utility purchases from qualifying facilities (" QFs ) in Idaho. As an electric utility with a legal obligation to purchase power from Idaho QFs, PacifiCorp has a direct and substantial interest in the outcome of this proceeding. One of the issues in this proceeding is whether the 10 MW ceiling for standard purchase rates should be interpreted on an average-megawatt basis with Page 2

3 respect to energy delivered rather than on a capacity basis. PacifiCorp participated in the proceeding that resulting in the 10 MW ceiling being adopted and must comply with that ceiling with respect to its standard QF purchases. Therefore, it has a direct and substantial interest in how the issue is resolved. As a potential purchaser from QFs, PacifiCorp now or in the future may be affected by the Commission s decisions on certain of the other practices that are at issue in this proceeding; therefore, it also has a direct and substantial interest with respect to those practices. PacifiCorp s participation in this proceeding will assist the Commission in resolving the issues before it and will not unreasonably broaden the issues, burden the record or delay the proceedings. No other party can adequately represent PacifiCorp s interests in this proceeding. PacifiCorp will accept the procedural schedule set forth in Order No issued by the Commission on June 8, PacifiCorp intends to file direct testimony as an intervenor on or before the August 5, 2004 deadline for intervenor testimony. WHEREFORE, PacifiCorp respectfully requests that the Commission grant this petition to intervene. DATED: July 6, es. Fell Attorneys for PacifiCorp Portlnd Page 3

4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 6th day of July 2004, I caused a true and correct copy of the foregoing Petition of PacifiCorp to Intervene to be served by the method indicated below, and addressed to the following: ConleyE. Ward Givens Pursley LLP 601 W Bannock Street PO Box 2720 Boise, ID Telephone: (208) cew~givenspursley.com Peter J. Richardson Richardson & O' Learly PLLC 99 East State Street Eagle, ID Telephone: (208) Fax: (208) peter~richardsonando leary. com Monica B. Moen, Attorney II Barton L. Kline, Senior Attorney Idaho Power Company PO Box 70 Boise, ID bkline~idahopower. com mmoen(q2idahopower. com Hand Delivery U. S. Mail (-to J Hand Delivery S. Mail (-X-J U. (-flj U. Hand Delivery S. Mail CERTIFICATE OF SERVICE Page 1

5 Doug Glaspey US Geothermal 1509 Tyrell Lane Boise, ID dglaspey~us geothermal. com J Hand Delivery LX.J U. S. Mail L~J Ja '. Fell CERTIFICATE OF SERVICE Page 2